Information Technology, Documents, & Records
Student records and data are accumulated and used by officials of the College only in pursuit of our educational mission and to fulfill necessary institutional record-keeping functions. These records, known as education records, are kept in different offices around the campus by several different custodians. Carleton students have a right to inspect and review their education records pursuant to the Carleton College Policy and Procedures on Education Records. If, upon review, a student discovers that an education record is inaccurate, misleading, or in violation of the student’s privacy rights or other rights, the student may request that the appropriate portion of the education record be amended.
Carleton College will refrain from disclosing any personally identifiable information contained in a student’s education records, except that certain information may be revealed with the consent of the student or as otherwise permitted by law.
Carleton specifically reserves the right to disclose “directory information” to any party without a student’s consent. “Directory information” includes information contained in an education record of a student which would not generally be considered harmful or an invasion of privacy if disclosed.
- name: the student’s full name
- addresses: permanent and local college and email address
- all telephone numbers of record
- date and place of birth
- major field of study, minor, certificate of advanced study in foreign language and literature or foreign language and area studies.
- participation in officially recognized activities and sports
- weight and height of members of athletic teams
- dates of attendance
- degrees and awards received
- most recent previous school attended
- photographs and video
- class year
- student ID number (The One Card issued to new students in the fall will show each student’s id number.)
Students nonetheless have a right to request that directory information be kept confidential. Such a request should be signed by the student and submitted in writing to the Dean of Students.
Students should understand that as long as their parents claim them as financial dependents the parents may have the right to access their education records. It is the policy of the College not to send parents information from education records without permission of the student except in the following cases: change of or jeopardy to a student’s academic status by action of the Academic Standing Committee; change of a student’s disciplinary status by action of the Dean of Students (or her/his designee) or the Judicial Hearing Board or the Academic Standing Committee; necessities of physical or emotional health; and parents’ inquiries about academic grades.
Students wishing to obtain a more detailed and comprehensive statement of their rights and responsibilities regarding education records may obtain a copy of the Carleton College Policy and Procedures on Education Records from the Dean of Students or may discuss any questions or concerns with the Dean. Any alleged failure to comply with the law regarding student records may be reported to the United States Department of Education.
Policies and Procedures Regarding Educational Records
For the purpose of this policy, we have used the following definitions of term:
- Student – any person who attends or has attended Carleton.
- Education Records – any record (handwritten, print, tape, film, or other medium) maintained by Carleton or an agent of Carleton which is directly related to a student, except:
- A personal record kept by a staff member if it is kept in the sole possession of the maker of the record and is not accessible or revealed to any other person except a temporary substitute for, or a permanent replacement for, the maker of the record.
- An employment record of an individual whose employment is not contingent on the fact that he or she is a student, provided the record is used only in relation to the individual’s employment.
- Records created and maintained by Carleton Security that were created for the purpose of law enforcement.
- Records maintained by the Health Services, the Counseling Center, or the Office of the Chaplain.
- Alumni records which contain information about a student after he or she is no longer in attendance at Carleton and which do not relate to the person as a student.
- Personally Identifiable Information – Information contained in any education record which reveals the identity of a student or from which the personal identity of a student could easily be traced. Personally identifiable information includes: (a) directory information, as described below, that may be disclosed without the specific consent of the student; and (b) information that will generally be disclosed only with such consent, e.g., social security numbers or class registration.
- Directory Information – Information contained in an education record of a student which would not generally be considered harmful or an invasion of privacy if disclosed. It includes: (a) student’s name; (b) permanent and local college addresses; (c) all telephone numbers of record; (d) date and place of birth; (e) major field of study and minor; (f) participation in officially recognized activities and sports; (g) weight and height of members of athletic teams; (h) dates of attendance; (i) degrees and awards received; (j) most recent previous school attended; (k) photograph; (l) class year; and (m) e-mail address. Regulations governing the release of this information may be found in the Disclosure Section.
- Party – an individual, agency, institution, or organization.
Right of Access and Limitations
- Carleton students have the right to review their own education records upon submitting a written request to do so.
- Carleton reserves the right to refuse to permit a student to inspect the following records:
- The financial statement of the student’s parents.
- Letters and statements of recommendation for which the student has waived his or her right of access, or which were placed in the file before January 1, 1975 (unless the letters were used for any purpose other than as recommendations).
- Letters and statements of recommendation placed in the education record after January 1, 1975 if (1) the student has waived the right to inspect and review these documents and (2) the documents were related to the student’s admission to an educational institution, application for employment, or receipt of an honor or honorary recognition.
- Records connected with an application to attend Carleton or a component unit of Carleton if that application was denied.
Those records as set forth in the definitions above that are excluded from the definition of “education records.”
Notwithstanding the last provision in 2. above, the College may not deny a student access to records maintained by the Health Service, the Counseling Center, or the Office of the Chaplain. These are not education records; access to them is guaranteed by Minnesota statute.
Right to Copies and Limitations
- Carleton will provide copies of education records to students after receiving a written request.
- The fee for copies will be 10¢ per page.
- The Registrar’s Office must have signed authorization from the student to release an official academic transcript. The authorization must include the student’s name, ID number and the address the transcript should be sent to. Allow four working days processing time.
- Carleton reserves the right to deny academic transcripts or copies of records in any of the following situations:
a. The student has an unpaid financial obligation to Carleton.
b. There is an unresolved disciplinary action against the student.
Types, Locations, and Custodians of Education Records
The following is a list of the types of education records that Carleton maintains, their locations, and their custodians.
Types Locations Custodian Admissions Records Office of the Dean of Students, Severance 110 Dean of Students Advising Files Office of the student’s Academic Advisor Academic Advisor Alumni Files Central Records Office, Leighton 129A Director of Central Records Cumulative Academic Records Office of the Registrar, Laird 7B
(for current students, graduates, and withdrawals)
Registrar Disciplinary Records Office of the Dean of Students, Severance 110 Dean of Students Financial Aid Records Office of Student Financial Services, Henry House Director of Student Financial Services Financial Records Controller’s Office, Leighton 109 Student Account Specialist Housing Office of Residential Life, Severance G10 Director of Residential Life Placement Records Career Center, Sayles-Hill 050 Director of the Career Center Progress Records Office of the Dean of Students, Severance 110 Dean of Students
Occasional Records: Student education records not included in the types listed above such as departmental memoranda, copies of correspondence in offices not listed, etc.
Location: The appropriate official will collect such records, direct the student to their location, or otherwise make them available for inspection and review.
Custodian: The Carleton staff person who maintains such occasional systems records.
Procedures to Inspect Education Records
Students may inspect and review their education records upon submitting a written request to the appropriate records custodian.
Students should submit to the appropriate records custodian (or to an appropriate Carleton staff person in the same office as the record custodian) a written request which identifies as precisely as possible the record or records the student wishes to inspect.
The records custodian or an appropriate Carleton staff person will make the needed arrangements for access as promptly as possible and notify the student of the time and place where the records may be inspected. (Carleton is required to provide access in 45 days or less from the receipt of the request.)
When a record contains information about more than one student, the student may inspect and review only that portion of the record that relates to himself or herself.
Disclosure Of Education Records To Third Parties
Carleton will disclose personally identifiable information from a student’s education record only with the written consent of the student, except in the following cases:
- Directory information, as defined above. Any student who wishes to designate directory information as confidential information not subject to disclosure should notify the Dean of Students in writing.
- To school officials who have a legitimate educational interest in the records.
- A school official is:
- A person employed by Carleton in an administrative, supervisory, academic or research position, or staff position—including a student employee—in support of one of these.
- A person elected to the Board of Trustees.
- Contractors, volunteers, and other non-employees performing institutional services and functions.
- A person who is employed by or under contract to Carleton, or who is appointed by a Carleton administrator, to perform a special task (such as an attorney, auditor, or judicial hearing board member).
- A school official has a legitimate educational interest if the official is:
- Performing a task that is specified in his or her position description or by a contractual agreement; or is within the scope of the usual duties performed by a person in that position.
- Performing a task related to a student’s education.
- Performing a task related to the discipline of a student.
- Providing a service or benefit relating to the student or student’s family, such as health care, counseling, job placement or financial aid.
- A school official is:
- To officials of another school, upon request, in which a student seeks or intends to enroll or is enrolled.
- To certain officials of the U.S. Department in Education, the Comptroller General, and state and local educational authorities, in connection with certain state or federally supported education programs.
- In connection with a student’s request for or receipt of financial aid, as necessary to determine the eligibility, amount or conditions of the financial aid, or to enforce the terms and conditions of the aid.
- If required by a state law requiring disclosure that was adopted before November 19, 1974.
- To organizations conducting certain studies for or on behalf of Carleton.
- To accrediting organizations to carry out their functions.
- To parents of an eligible student who claim the student as a dependent for income tax purposes.
- To comply with a judicial order or a lawfully issued subpoena.
- To appropriate parties in a health or safety emergency.
- To an alleged victim of any crime of violence, the results of any disciplinary proceeding conducted by Carleton against the alleged perpetrator of that crime.
- As of January 3, 2012, the U.S. Department of Education’s FERPA regulations expand the circumstances under which your education records and personally identifiable information contained in such records — including your Social Security Number, grades, or other private information — may be accessed without your consent. First, the U.S. Comptroller General, the U.S. Attorney General, the U.S. Secretary of Education, or state and local education authorities (“Federal and State Authorities”) may allow access to your records and personally identifiable information without your consent to any third party designated by a Federal or State Authority to evaluate a federal- or state-supported education program. The evaluation may relate to any program that is “principally engaged in the provision of education,” such as early childhood education and job training, as well as any program that is administered by an education agency or institution. Second, Federal and State Authorities may allow access to your education records and personally identifiable information without your consent to researchers performing certain types of studies, in certain cases even when we object to or do not request such research. Federal and State Authorities must obtain certain use-restriction and data security promises from the entities that they authorize to receive your personally identifiable information, but the Authorities need not maintain direct control over such entities. In addition, in connection with Statewide Longitudinal Data Systems, State Authorities may collect, compile, permanently retain, and share without your consent PII from your education records, and they may track your participation in education and other programs by linking such personally identifiable information to other personal information about you that they obtain from other Federal or State data sources, including workforce development, unemployment insurance, child welfare, juvenile justice, military service, and migrant student records systems.
Record of Requests for Disclosure
Carleton will maintain a record of all (1) requests for disclosure of and (2) actual disclosures of, information from a student’s education records. The record will indicate the name of the party making the request, any additional party to whom it may be redisclosed, and the legitimate interest the party had in requesting or obtaining the information. The record of disclosures or requests for disclosure may be reviewed by the student.
Retention of Student Records
In general, education records are retained only as long as it is necessary to serve the student’s interest or further the necessary administrative functioning of the College. Academic records and a core set of the student record files maintained by the Dean of Students are designated as permanent records. The student’s personal file is maintained by the Dean of Students for 1-5 years after the student’s graduation or separation from the College, at which time it is cleared of all but the admissions application, directory information, campus job evaluations, notices of awards or honors, a list of extracurricular activities, and information provided by the student which is indicative of post-college activities. At that time the file is transferred to the alumni files maintained by the Central Records Office.
Records of disciplinary status up to and including disciplinary probation are maintained until graduation or until two years after withdrawal from the College; records of disciplinary suspensions, both academic and nonacademic, are maintained for five years; and records of expulsion are kept for ten years.
[Disciplinary record retention updated by The Board of Trustees on recommendation of The College Council May, 2003]
Correction of Education Records
Students have the right to ask to have records corrected if they believe that the records are inaccurate, misleading, or in violation of their privacy rights. The procedure for correcting education records is as follows:
- A student must ask the appropriate custodian to amend a record. In so doing, the student should identify the part of the record he or she wants changed and specify why it is believed to be inaccurate, misleading or in violation of his or her privacy or other rights.
- Carleton may comply with the request or it may decide not to comply. If it decides not to comply, Carleton will notify the student of the decision at his or her last known address of record and advise the student of the right to a hearing to challenge the information believed to be inaccurate, misleading, or in violation of the student’s rights.
- A written request for a hearing must be submitted to the custodian of the record in question. Carleton will arrange for a hearing on the matter and will notify the student, reasonably in advance of the hearing, of the date, place, and time that the hearing will be held.
- The hearing will be conducted by the Judicial Hearing Board (JHB). The student shall be afforded a full and fair opportunity to present evidence relevant to the issues raised in the original request to amend the student’s education records. The student may be assisted by one or more individuals, including an attorney.
- The Chair of the JHB will prepare a written decision based solely on the evidence presented at the hearing. The decision will include a summary of the evidence presented and the reasons for the decision. A copy of the written decision will be provided to the student at his or her last known address of record within a reasonable time after the hearing, usually in ten academic days unless circumstances require a longer period for a decision to be prepared.
- If the JHB decides that the challenged information is not inaccurate, misleading, or in violation of the student’s right of privacy, they will notify the student of the right to place in the education record a statement commenting on e challenged information and/or a statement setting forth reasons for disagreeing with the decision.
- The statement will be maintained as part of the student’s education records as long as the contested portion is maintained If Carleton discloses the contested portion of the record, it must also disclose the student’s statement.
- If Carleton decides that the information is inaccurate misleading, or in violation of the student’s right of privacy, it will amend the record and notify the student, in writing at his or her last known address on record, that the education record has been amended.
Students will be notified of their FERPA rights annually via the Student Handbook which is in electronic form (hard copy on closed reserve in the library).
Application of this Policy
This policy shall be applied in accordance with the written Guidelines for Records Custodians. Questions or concerns about this policy and its interpretation should be directed to the Dean of Students.
Adopted by the College Council, November 8, 1993
Updated October 9, 2002
Revised by the Board of Trustees on recommendation of College Council, June, 2003
Adopted by the Board of Trustees June 17, 1993, upon recommendation of the College Council.
Reviewed and updated June, 2012.
Maintained by: Dean of Students Office
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